INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
May 25, 2022

GENERAL FACILITY INFORMATION

Facility Name:  DAK Americas Mississippi Inc
Facility Address:  
3303 Port and Harbor Drive
Port Bienville Industrial Park
Bay St. Louis, MS 39520    
County: Hancock
SIC Code(s): 2821
NAICS Code(s): 325211  

APPLICATION SUMMARY
 
Permit No.: 1000-00039
Permit Action:  Renewal
Permit Folder: PER20210003
Application Receipt Date: February 26, 2021
Application Deemed Complete: 
CBI Submitted?: No	NSPS (Part 60): Subpart Dc
NESHAP (Part 61): N/A
NESHAP (Part 63): Subpart ZZZZ, Subpart JJJ, Subpart DDDDD
112(r) / RMP: N/A
Other: N/A	
FACILITY DESCRIPTION

DAK Americas Mississippi Inc. operates an existing polyethylene terephthalate (PET) bottle resin and PET staple fiber facility.  Three production lines were originally constructed – two (H1/P1, H2/P2) for bottle resin manufacturing and one (L1/Spin-Draw-Bale) for staple fiber production.  Line L1 will feed the proposed Spin-Draw-Bale to produce staple fiber and simultaneously produce staple fiber chip.  As an alternate operating scenario, Line L1 could instead feed P3, as currently configured.  P3 can also be operated independently, fed with polymer from H1, H2, or purchased feed resin.  In addition, NOx and CO emissions for the natural gas-fired heaters and boilers have been updated using emission factors from a stack test instead of AP-42 emission factors.  DAK operates boilers, heat transfer medium (HTM) heaters, raw material and product storage and conveying lines, and other associated conveying equipment.

TITLE V SOURCE APPLICABILITY 

DAK is a major source as defined by Title V of the Federal Clean Air Act due to its potential to emit more than 10 tons per year of each of the following hazardous air pollutants (HAPs):  ethylene glycol and acetaldehyde; and 25 tons per year of total hazardous air pollutants.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	44.79	
PM10	44.79	
PM2.5	15.05	
Sulfur Dioxide (SO2)	2.28	
Nitrogen Oxides (NOx)	90.32	
Carbon Monoxide (CO)	89.70	
Volatile Organic Compounds (VOC)	66.39	
Total Reduced Sulfur (TRS)	n/a	
Lead	n/a	
CFC/HCFC	n/a	
Total HAP 	47.53	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY

The facility is one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the PSD threshold for a major source is 100 tpy.  The facility has the potential to emit less than 100 tpy of each of the regulated NSR pollutants; therefore, it is an existing minor source under the PSD program.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES

No major process changes have been made at the facility since the previous Title V Operating Permit renewal and 2013 color sorter permit modification.  One minor operating change is that talc additive is no longer used at the dump stations.  

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY

40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

Emission Points AA-001, AA-002, and AA-003, three 68 MMBTU/Hr Heat Transfer Medium (HTM) Heaters, are subject to federally enforceable emission limitations for nitrogen oxide and carbon monoxide. These units do not use control devices; therefore CAM is not applicable.

Emission Points AA-004, AA-005, and AA-006, three 100 MMBTU/Hr Boilers, are subject to federally enforceable emission limitations for nitrogen oxide and carbon monoxide. These units do not use control devices; therefore CAM is not applicable.

For Emission Points AB-005, AB-007, AB-008, AB-009, AB-010, AC-005, AC-007, AC-009, AD-006, and AF-005, the baghouses and cyclones remove fines that can foul process equipment and recover product and reintroduce it to the process. The baghouses and cyclones are considered inherent to each process. Each process would not operate without this equipment in place; therefore CAM does not apply to the PM emissions control equipment.  (This determination was made during the initial Title V issuance for this facility.)

Emission Points AB-001, AC-001, AD-001, AE-001, and AG-001, are subject to a promulgated MACT standard which require control measures for the criteria pollutant VOC. MACT monitoring satisfies CAM requirements, therefore the CAM rule imposes no additional monitoring.

Remaining PM emission sources have pre-controlled emissions less than the major source thresholds; therefore, CAM is not applicable.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 63, Subpart JJJ – National Emission Standards for Hazardous Air Pollutants Group IV Polymers and Resins – Emission Points AB-001, AC-001, AD-001, AE-001, and AG-001 are subject to this subpart.  All applicable requirements are included in the permit.

40 CFR 63, Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines – Emission Points AA-007, AA-009, AA-010, and AA-021 are subject to this subpart.  All applicable requirements are included in the permit.

40 CFR 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources:  Industrial, Commercial, and Institutional Boilers and Process Heaters – Emission Points AA-004, AA-005, AA-006, AA-011, AA-012, and AA-013 are subject to this subpart.  All applicable requirements are included in the permit. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
40 CFR 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units – Emission Points AA-001, AA-002, AA-003, AA-004, AA-005, and AA-006 are subject to this subpart.  All applicable requirements are included in the permit.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001  AA-002  AA-003  AA-004  AA-005 AA-006	PM (filterable only)	E = 0.8808*I-0.1667	Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period.	
AA-001  AA-002  AA-003  AA-004  AA-005 AA-006  AA-011  AA-012  AA-013	SO2	4.8 lbs/MMBTU		
AA-001  AA-002  AA-003 (Emission limits are combined)	NOx	9.90 lbs/hr (maximum hourly) and 36.25 tpy	Stack test one of the three heaters once per permit term.

Calculate and record monthly NOx and CO emissions.	
	CO	9.90 lbs/hr (maximum hourly) and 36.25 tpy		
	Natural Gas Usage	< 1,450 MMcf/yr	Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period.	
AA-001  AA-002  AA-003  AA-004  AA-005 AA-006	NSPS Subpart Dc	These units only have to comply with daily fuel combustion records.

Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period..	
AA-004  AA-005 AA-006  (Emission limits are combined)	NOx	14.56 lb/hr (maximum hourly) and 50.0 tpy	Stack test one of the three boilers once per permit term.

Calculate and record monthly NOx and SO2 emissions.	
	CO	14.56 lb/hr (maximum hourly) and 50.0 tpy		
	Natural Gas Usage	< 2,000 MMcf/yr	Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period.	
AA-007  AA-009 AA-010  AA-011  AA-012  AA-013 AA-021	PM (filterable only)	0.6 lbs/MMBTU	Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period.	
AA-007	Diesel Fuel Usage	< 3,840 gallons/yr	Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period.	
AA-009  AA-010 (combined usage)	Diesel Fuel Usage	< 2,496 gallons/yr	Record and maintain the amount of fuel combusted during each day and in any 12-month rolling period.	
AA-007  AA-021	MACT Subpart ZZZZ	Change oil and filter every 500 hours; inspect air cleaner every 1,000 hours; and inspect all hoses and belts every 500 hours.

Maintain and record to document hours of operation on a daily basis and any consecutive 12-month period.

Comply with all applicable requirements of 40 CFR 63, Subpart ZZZZ	
AB-002	PM/PM10 (filterable only)	0.21 lb/hr and 0.94 tpy	Perform regular inspections for any required maintenance each week or more often if necessary to maintain proper operation of the pollution control equipment.

Conduct weekly inspection for visible emissions.

Stack test one of the two polymerization lines once per permit term.	
AB-003	PM/PM10 (filterable only)	0.21 lb/hr and 0.94 tpy		
AB-004	PM/PM10 (filterable only)	0.65 lbs/hr and 2.83 tpy		
AB-005	PM/PM10 (filterable only)	0.07 lbs/hr and 0.30 tpy		
AB-006	PM/PM10 (filterable only)	0.12 lbs/hr and 0.51 tpy		
AB-007	PM/PM10 (filterable only)	0.10 lbs/hr and 0.44 tpy		
AB-008	PM/PM10 (filterable only)	0.90 lbs/hr and 3.94 tpy		
AB-009	PM/PM10 (filterable only)	0.05 lbs/hr and 0.23 tpy		
AB-010	PM/PM10 (filterable only)	0.10 lbs/hr and 0.44 tpy		
AB-011  AC-011  AF-001  AF-002  AF-003  AF-004  AH-001  AH-002  AH-003  AH-004  AH-005 AH-006	PM/PM10 (filterable only)	E = 4.1p0.67	Perform regular inspections for any required maintenance each week or more often if necessary to maintain proper operation of the pollution control equipment.

Conduct weekly inspection for visible emissions.	
AC-002	PM/PM10 (filterable only)	0.21 lbs/hr and 0.94 tpy	Perform regular inspections for any required maintenance each week or more often if necessary to maintain proper operation of the pollution control equipment.

Conduct weekly inspection for visible emissions.

Stack test one of the two polymerization lines once per permit term.	
AC-003	PM/PM10 (filterable only)	0.21 lbs/hr and 0.94 tpy		
AC-004	PM/PM10 (filterable only)	0.65 lbs/hr and 2.83 tpy		
AC-005	PM/PM10 (filterable only)	0.07 lbs/hr and 0.30 tpy		
AC-006	PM/PM10 (filterable only)	0.12 lbs/hr and 0.52 tpy		
AC-007	PM/PM10 (filterable only)	0.10 lbs/hr and 0.44 tpy		
AC-008	PM/PM10 (filterable only)	0.90 lbs/hr and 3.94 tpy		
AC-009	PM/PM10 (filterable only)	0.05 lbs/hr and 0.23 tpy		
AC-010	PM/PM10 (filterable only)	0.10 lbs/hr and 0.44 tpy		
AD-002	PM/PM10 (filterable only)	0.027 lbs/hr and 0.118 tpy	Perform regular inspections for any required maintenance each week or more often if necessary to maintain proper operation of the pollution control equipment.

Conduct weekly inspection for visible emissions.

Stack test one of the two polymerization lines once per permit term.	
AD-003	PM/PM10 (filterable only)	1.07 lbs/hr and 4.69 tpy		
AD-004	PM/PM10 (filterable only)	0.54 lbs/hr and 2.35 tpy		
AD-005	PM/PM10 (filterable only)	0.12 lbs/hr and 0.51 tpy		
AD-006	PM/PM10 (filterable only)	0.46 lbs/hr and 2.01 tpy		
AD-007	PM/PM10 (filterable only)	0.21 lbs/hr and 0.91 tpy		
AD-008	PM/PM10 (filterable only)	0.27 lbs/hr and 1.18 tpy		
AB-001  AC-001  AD-001  AE-001 AG-001	HAP	> 98 % or 20 ppmv, whichever is less stringent	Comply with all applicable requirements of 40 CFR 63, Subpart JJJ
Route all emissions to Emission Points AA-001 through AA-004
	
		Equipment Leaks		
		Pressure Relief Devices		
AG-001	HAP	Wastewater Provisions	Comply with all applicable requirements of 40 CFR 63, Subpart JJJ
	
		Maintenance Wastewater Provisions		
AB-007  AC-007  AD-006		Vents shall remain closed during normal operations.		
AA-004  AA-005  AA-006  AA-011  AA-012  AA-013	HAP	Annual Tune-up	Comply with all applicable requirements of 40 CFR 63, Subpart DDDDD	
		Good Air Pollution Control Practices